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IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

W.P. No._____________/2001

Ghulam Muhammad S/o Muhammad Ramzan, caste Khokhar, R/o


Chah Nehlay Wala, Mouza Gith Brabar, Tehsil & District Multan.
Petitioner
VERSUS
1. S.H.O. Police Station Alpa.
2. Zafar Iqbal
3. Pevaiz Iqbal Sons of Abdul Sattar, caste Arain
4. Amjad Iqbal
5. Shahid S/o unknown, caste Arain.
6. Riaz Shah S/o unknown, caste Syed.
Respondents No. 2 to 6 residents of Chah Nehlay Wala,
Mouza Gith Brabar, Tehsil & District Multan.
Respondents

Writ Petition under Article 199 of


the Constitution of Islamic
Republic of Pakistan, 1973 read
with all enabling provisions of law.

Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.
2. That the petitioner is an employee of one Sardar Ghulam Hussain
Khan Khizar, who is a land-lord of Mouza Gith Brabar. The
petitioner looks after the lands of said Sardar Ghulam Hussain
Khan Khizar. The said land-lord had sold two acres of land to the
respondents No. 2 & 3; and the respondents had installed a
cosmetics factory upon that piece of land. The respondents No. 2
to 4 tried many times to enforce unauthorised possession on more
land and encroach the road as well, but were stopped by the
land-lord; and the petitioner was directed to take care of it also.

3. That on 24.4.2001, the petitioner received an information that the


respondents No. 2 to 4 are constructing a sewerage tank in the
mid of road. The petitioner reached at the spot and refrained the
labour to do so. They stopped the work and informed the owners
of factory. After a while, the respondents No. 2 to 6 armed with
sotas, sarya and wooden phatties came there. Amjad inflicted a
sarya blow on the head of petitioner and the petitioner fell down
on the ground, then Shahid and Riaz Shah inflicted sota and
phatty blows on the right arm and back of the petitioner. Nazar
Hussain son of Muhammad Bakhsh and Maqbool Hussain son of
Gul Muhammad, caste Khokhar residents of the same village,
when passing beside the spot, tried to escape the petitioner, on
which Zafar Iqbal with iron teshi injured the leg of Nazar
Hussain while Amjad caused injury on the head of Maqbool by
brick; and Riaz Shah caused injury on the left arm of Maqbool.
On hue and cry of injured persons, residents of the village and
Khizar Khan attracted towards the place of occurrence. On their
interference, the respondents No. 2 to 6 called the workers of
factory. Amjad and Shahid threatened the Khan Sahib to done to
death and tried to assault the Khan Sahib, but could not succeed.
The petitioner along-with Nazar & Maqbool were taken to
Nishtar Hospital and were examined by the doctors.

4. That the petitioner appeared before the respondent No. 1 with


the Medico-legal Certificates to lodge a report against the
respondents No. 2 to 6, but he refused to initiate any type of legal
proceedings against them. Aggrieved by the conduct of
respondent No. 1, the petitioner appeared before the D.S.P./
S.D.P.O. concerned with an application and Medico-legal
Certificates, who was kind enough to direct the respondent No. 1
as under: -

D.S.P. Sadar, Multan.

24.4.2001

Copies of application and Medico-legal Certificates are


Annexes “A, B, C & D”.

5. That the respondent No. 1 received the application and


Medico-legal Certificates, but did not register the case against
respondents No. 2 to 6, because of their influence and
relations with high-ups. The petitioner requested the
respondent No. 1 many times to act upon the direction of
D.S.P., but he always remained reluctant; and now has refused
to register the case and returned the original documents.

6. That the petitioner is left with no other adequate, efficacious


and speedy remedy except to invoke the extra-ordinary
constitutional jurisdiction of this Hon’ble Court for the
redressal of his grievance.

Keeping in view the above-mentioned facts, it is


respectfully prayed that the respondent No. 1 may
please be directed to act upon the order of D.S.P. Sadar
dated 24.4.2001 and register a case against the
respondents No. 2 to 6 as well, by receiving the original
application and Medico-legal Certificates.
Any other writ, order, direction or relief which
this Hon’ble court deems fit, may please be extended in
the favour of petitioner to meet the ends of justice.

HUMBLE PETITIONER,
Dated: 01.9.2001

Through: -
Hammad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959

CERTIFICATE: -
Certified as per instructions of the client,
that this is the first petition on the subject
matter. No such petition has earlier been
filed before this Hon’ble Court.
Advocate

IN THE LAHORE HIGH COURT, MULTAN BENCH,


MULTAN.
W.P. No. ______________/2001

Ghulam Muhammad Vs. S.H.O. etc.

AFFIDAVIT of: -
Ghulam Muhammad S/o Muhammad Ramzan, caste
Khokhar, R/o Chah Nehlay Wala, Mouza Gith Brabar,
Tehsil & District Multan.

I, the above named deponent do hereby


solemnly affirm and declare that the contents of
the above-mentioned petition are true and correct
to the best of my knowledge and belief and
nothing has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of September 2001 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief.

DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH,


MULTAN.
In re: C.M. No. _____________/2001
In
W.P. No.____________/2001

Ghulam Muhammad Vs. S.H.O. etc.

APPLICATION FOR DISPENSING WITH THE


FILING OF CERTIFIED COPIES OF ANNEXURES.
=========================================

Respectfully Sheweth:-
That certified copies of Annexes “A to D” are not
available. However, uncertified/photo state copies of the
same have been annexed with the petition, which are true
copies of original documents.

It is, therefore, respectfully prayed that this Hon’ble


court may please dispense with the filing of aforesaid copies
of documents.
APPLICANT

Dated: __________

Through: -
Hammad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959

IN THE LAHORE HIGH COURT, MULTAN BENCH,


MULTAN.
In re: C.M. No. _____________/2001
In
W.P. No.____________/2001

Ghulam Muhammad Vs. S.H.O. etc.

DISPENSATION APPLICATION.

AFFIDAVIT of: -
Ghulam Muhammad S/o Muhammad Ramzan, caste
Khokhar, R/o Chah Nehlay Wala, Mouza Gith Brabar,
Tehsil & District Multan.

I, the above named deponent do hereby


solemnly affirm and declare that the contents of
the above-mentioned application are true and
correct to the best of my knowledge and belief
and nothing has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of September 2001 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief.
DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH,


MULTAN.
W.P. No.____________/2001

Ghulam Muhammad Vs. S.H.O. etc.

INDEX

S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES


1 Urgent Form __
2 Stamp Paper worth Rs. 500/- __
3 Writ Petition. 1-7
4 Affidavit 9
5 Copy of Application. A 11
6 Copies of Medico-legal Certificates. B, C & D 13-17
7 Dispensation Application. 19
8 Affidavit. 21
9 Vakalatnama 23

PETITIONER
Dated: ____________

Through: -
Hammad Afzal Bajwa,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20959

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